Michael Ramos v. Amy Michelle Hunter - Paternity Case
Summary
The Florida District Court of Appeal reversed an amended paternity judgment and parenting plan in Michael Ramos v. Amy Michelle Hunter. The court found that while the Parental Relocation Act did not apply, the trial court erred by granting majority timesharing without proper notice to the appellant.
What changed
The Florida District Court of Appeal has reversed an amended judgment of paternity and parenting plan in the case of Michael Ramos v. Amy Michelle Hunter (Docket No. 4D2025-0369). The appellate court affirmed the lower court's decision that the Florida Parental Relocation Act did not apply, as the move occurred before the paternity action was filed. However, the court reversed the grant of majority timesharing to the appellee, Amy Michelle Hunter, because Ramos was not given adequate notice that this relief would be sought or considered at the hearing.
This decision means the case will be remanded for further proceedings where both parties will have the opportunity to address timesharing. Compliance officers should note that procedural fairness, including proper notice of relief sought, is critical in family law proceedings. While this is a specific court case, it highlights the importance of due process in determinations of child custody and timesharing, which could have implications for how similar cases are handled in Florida courts.
What to do next
- Review case file for procedural notice requirements in paternity and custody matters.
- Ensure all parties are provided with adequate notice of relief sought in future family law proceedings.
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March 11, 2026 Get Citation Alerts Download PDF Add Note
Michael Ramos v. Amy Michelle Hunter
District Court of Appeal of Florida
- Citations: None known
- Docket Number: 4D2025-0369
Disposition: Affirmed
Disposition
Affirmed
Combined Opinion
DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA
FOURTH DISTRICT
MICHAEL RAMOS,
Appellant,
v.
AMY MICHELLE HUNTER,
Appellee.
No. 4D2025-0369
[March 11, 2026]
Appeal from the Circuit Court for the Fifteenth Judicial Circuit, Palm
Beach County; Cheryl A. Carazo, Judge; L.T. Case No.
502023DR010438XXXANB.
Caryn A. Stevens, Diana M. Minnocci, and Eddie Stephens of Stephens
& Stevens, PLLC, West Palm Beach, for appellant.
David Lloyd Merrill of The Associates, Palm Beach Gardens, for
appellee.
PER CURIAM.
Michael Ramos appeals an amended judgment of paternity and
parenting plan. The amended judgment established a long-distance
parenting plan that awarded Amy Michelle Hunter majority timesharing
with the parties’ two minor children. Ramos raises two issues on appeal.
We reverse and remand for further proceedings.
First, Ramos argues the circuit court incorrectly concluded the Florida
Parental Relocation Act, Section 61.13001, Florida Statutes (2025), did not
apply. On that issue, we affirm. The circuit court correctly applied
controlling precedent and concluded that section 61.13001 does not apply
to this case because Hunter moved the child before Ramos filed the
paternity action. See Essex v. Davis, 116 So. 3d 445 (Fla. 4th DCA 2012)
(explaining that under Section 61.13001, Florida Statutes, the 2009
amendment changed the definition of “relocation” from a change in the
child’s residence to the parent’s principal residence, and holding the
statute inapplicable where the parent moved prior to the filing of the
action). As a result, the circuit court correctly treated Ramos’ request as
part of an initial timesharing determination under Section 61.13(3),
Florida Statutes (2025).
While we agree with the circuit court’s statutory conclusion, we still
must reverse. For his second issue, Ramos argues the circuit court erred
when it granted Hunter majority timesharing, relief that Hunter neither
requested nor noticed for hearing. It was not until opening statement at
the hearing that Hunter’s counsel stated Hunter was seeking majority
timesharing. At that time, Ramos’ counsel objected and noted that Hunter
had not requested majority timesharing prior to the hearing. In fact,
Hunter had requested equal timesharing prior to the hearing. We
acknowledge the circuit court was attempting to fulfill its statutory
obligation to act in the best interest of the child. However, Ramos was
entitled to notice that Hunter intended to seek majority timesharing at the
scheduled hearing. Without notice that the issue was going to be
addressed at the hearing, Ramos was not prepared to present evidence in
support of majority timesharing.
As a result, we reverse. We express no opinion on the merits of any
timesharing award that is rendered after both parties are afforded notice
and an opportunity to be heard.
Affirmed in part, reversed in part, and remanded.
KUNTZ, C.J., CIKLIN and SHAW, JJ., concur.
Not final until disposition of timely-filed motion for rehearing.
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